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Well, well, the TOCs are taking on the safety Taleban at last
As the count down on this page reminds us there are just 414 days to go before Mk 1 electric multiple units must be fitted with anti-overide protection or be withdrawn from service. Or must they? According to Informed Sources, the three train operators involved are still arguing with Her Majesty's Railway Inspectorate over the issue.
So when the Editor referred to ‘cup & cone roulette' in the count down window he was remarkably prescient (that's enough sucking up –Ed) and time is running out. The Rolling Stock Companies which own the Mk 1 stock in service with South West Trains, Network South Central and Connex South Eastern are concerned that their installation schedules to fit ‘cup & cone' during routine maintenance will no longer be able to meet the deadline if the debate goes on much longer. One Informed sources told me, ‘We had hoped to start fitting in January. If we don't, it could get tight'.
Remember that under the Railway (Safety) Regulations 1999, Mk1 stock has to be fitted with an approved anti over-ride system by December 31 2002 , if it is to remain in service. Cup & cone, developed for the HMRI by WS Atkins. complies with the regulations.
However, as described in the Informed Sources cup & cone special (Month 2001) the modification itself introduces further risk. For starters, the inter-unit gangway connection has to be removed and the end doors closed-off. This prevents passengers walking through coupled trains, resulting in local overcrowding. Drivers have to change ends walking on the ballast, which is more dangerous, although no one can remember the last injury from such a cause.
So if you don't want to fit cup & cone, and the safety benefit is already minimal, pointing out that it introduces new risk is a good starting point. And the resistance has been strengthened by the admission that in addition to creating new operational risks, full scale testing has shown that the system is only 60% as effective as first thought.
So even now, HSBC, the lead ROSCO on the modification, together with WS Atkins, are analysing the roles of the four elements of cup and cone to see whether any could be safely dispensed with. These elements are the cup & cone themselves, the removal of buffers to so that the cup and cone can be fitted in their place, the closure of the gangway and the cutting away of sections of the underframe to produce controlled collapse in a collision.
Currently three options are being considered.
1 Implement cup & cone with mitigation of the imported operational risks;
2 Develop and implement an alternative solution within the timescale of the Regulations
3 Seek an exemption to the regulations through consultation
Option 1 could avoid some of the imported operational risk by, for example, retaining the through gangway connection. But of course, the gangway was removed for a reason. Tests showed that the gangway buffers affected the energy absorbing controlled collapse of the vehicle end, making the impact more abrupt.
This option would mean the HMRI having to make a decision on whether the risk reduction achieved still satisfied the spirit of the regulations.
Given that time is running out fast, Option 2 looks pretty high risk. So now there is talk of the simplified modification implied in Option 1 being used to support an application for exemption (option 3)
For example, the TOCs would need to demonstrate that the revised modification was the best compromise and reduced the combined collision and imported risk to As Low As Reasonable Practicable. Then they could argue that the Mk 1 fleet is being withdrawn faster than was expected since the regulations were made. Since cup & cone works only if two Mk 1 units collide, the benefits shrink with the size of the fleet.
In parallel, the introduction of the Train Protection & Warning System further reduces the risk of collision. And, of course, the current Mk 1 stock replacement programme gives an effective guarantee that if the new trains work, Mk1s will be gone by December 2004.
So, a commonsense solution to a waste of money?. Yes, but remember that the Health & Safety Executive has criticised sophisters in the Railway industry for using Cost Benefit Analysis to justify <ital>not<ital> making safety improvements which were of marginal value. Safety at any price is the HSE's approach to Railways.
So an approach by the TOCs based on CBA and ALARP would be embarrassing to Rose Court . But with time running out fast, the even greater prospective embarrassment of commuter services halting if an agreement is not reached by December 31 2002 could lead to political pressure on the HSE to leave unmodified Mk 1 stock in service to the end of its short remaining life span.
Political pressure on our safety Regulator? Perish the thought! This column looks to Stephen Byers to do his duty and call in Vic Coleman and, err, have another one of his non-threatening conversations.